a. Our
Commitment to Privacy

Sonae
SGPS, S.A. processes personal data with transparency and security. We apply
this commitment in our daily relationship with our investors, business partners,
customers and suppliers. Privacy and security of data entrusted to us is a
priority.

We
are committed to collect, store, process, transfer and erase personal data of
our investors, business partners, customers and suppliers only in a transparent
way and when they are needed to offer our best services. We inform you of how
we use your personal data and for what purposes, assuring that we collect,
share and store those data applying security and data protection best
practices.

When
your personal data are collected, stored, processed, transferred or erased by
third parties, we demand the same level of privacy and security.

We
want you to feel confident that your data are safe with us, since we will
always be committed to protect your privacy, and take very seriously our
responsibilities on the protection of your personal data.

Whenever
you have any question on the use we make of your personal data we will be available
to help you through the following channels:

You
may also contact our Data Protection Officer using the same address and the
electronic mail dpo@sonae.pt.

b.Who is
Responsible for Your Personal Data

SONAE
SGPS, S.A., with head office at Lugar do Espido, Via Norte,
4470-909 Maia, registered with the Registrar of Companies with registration number
500 273 170, with a share capital of €2.000.000.000,00,(SONAE), is responsible for processing your personal data under the terms of
the General Data Protection Regulation and of related local data protection
laws applicable in the countries in which it operates.

iii. Supplier
data – in the case of individuals, full name and tax number; in the case of
companies, name and contact of representatives;

iv. Business
Partners data – in the case of individuals, full name and tax number; in the
case of companies, name and contact of representatives.

d.How
and Why We Use Your Personal Data

We
use your personal data with the following purposes:

- To
give you information requested by you as an investor/shareholder and for internal
reporting purposes;

- To
implement actions resulting from Corporate Social Responsibility partnerships;

- To
comply with regulatory reporting requirements;

- To
implement communication and brand initiatives and projects.

e.For
How Long Do We Keep Your Personal Data

We
only keep your personal data for as long as we need to achieve the purposes
stated in the previous paragraph and to comply with law.

When
the maximum retention period is attained, your personal data are anonymized or
destroyed/erased in a secure manner.

f.With
Whom May We Share Your Personal Data

In
some cases, we may share your personal data with other Sonae Group companies.
In those cases, we require that these companies have in place appropriate security
measures to protect your personal data.

When required
by law, we may have to share your personal data with legal authorities or third
parties. In these cases, our control over the protection of your personal data
is limited.

g.How
You May Exercise Your Personal Data Protection Rights

Under
certain circumstances, you have the right to request from us:

i. Additional
information on how we use your personal data;

ii. Access
to your personal data;

iii. That
we transfer to a third party the personal data you gave us;

iv. That
we update your personal data;

v. That
we erase your personal data;

vi. That
we suspend processing of your personal data once you opposed to it;

vii. That
we limit how we use your personal data, whilst we correct them or we clarify
any doubts we may have on their content or the way we use them;

viii. That
we provide adequate means to enable you to object to decisions based solely on
automated processing of your data.

You
also have the right to withdraw, at any moment, the consent which you may have
given us to use your personal data, when this use is based on consent.

You
may not exercise these rights when your personal data are used to protect
public interest, namely when used for crime investigation and prevention, or
when subject to professional confidentiality.

To
exercise your data protection rights or whenever you have any question on the
use we make of your personal data you should contact us through the following
channels:

You
may also contact our Data Protection Officer using the same address and the
electronic mail dpo@sonae.pt.

Should
you be dissatisfied with how we use your personal data or with our response to
your request to exercise your rights, you may file a complaint with Comissão
Nacional de Proteção de Dados (CNPD) – Address:
Rua de São Bento, 148 – 3º, 1200-821 Lisboa – Telephone: +351213928400 –
Telefax: +351213976832 – Electronic mail: geral@cnpd.pt.

h.How Do
We Protect Your Personal Data

Sonae,
SGPS, SA has implemented several security measures, in line with best national
and international practices, which enable the protection of your personal data.
This includes technological controls, administrative, technical and physical
measures and procedures which ensure the protection of your personal data, and
prevent improper use, unauthorized access and disclosure, loss, improper or
negligent modification, or unauthorized destruction of personal data. In terms
of data security, we apply the same principles of continuous improvement which
we use in all our daily activities.

Amongst others, we highlight the following security measures:

i. Access
to your personal data is restricted to those who need them for the purposes
stated above;

i.Updates
to this Privacy Policy

This Privacy Policy may be updated from time to time. Updates will
be made available on our website.

Cookies and Privacy and Security Policy

What is a Cookie?

A cookie is a file that is written onto your computer or any other device used to access certain webpages that allows to collect information about your browsing activities. In some cases, Cookies are necessary to enhance browsing experience while allowing to store and recover information about the user’s browsing habits or equipment, among others. Depending on the information contained and how equipment is used, cookies can be allow to recognise users.

Types of Cookies used

Session Cookies –
These are temporary files that are created and only available until
users close their browser. When users access their browser again,
cookies will no longer be stored. The information obtained allows to
manage sessions, identify problems and provide an improved browsing
experience.

Performance Cookies -
These cookies are used to analyse the use of our website, allowing to
feature items or services tailored to our users’ interests, while
monitoring the website performance, knowing which pages are most
popular, what is the most effective method to link pages or determining
why some pages report error messages. These cookies are used only to
create and analyse statistic data, never collecting any personal data.

Functionality Cookies
– Functionality cookies allow us to remember users and tailor our
website to their browsing preferences. This way there is no need to
reset preferences or customise profiles whenever visiting it.

Disabling Cookies

Users
may allow, block or delete Cookies placed on their devices in the
settings menu of the browser installed in their computers. Please read
the Help tab of your browser to learn more about how to enable "private
browsing” or to disable certain Cookies.

Internet Explorer: Tools
-> Internet Options -> Privacy -> Settings. For more
information, please check out Microsoft Support or the Help tab on your
browser.

Firefox: Tools
-> Options -> Privacy -> History -> Custom Settings. For
more information, please check out Mozilla Support or the Help tab on
your browser.

Chrome: Settings
-> Show advanced settings -> Privacy -> Content settings. For
more information, please check out Chrome Help Center or the Help tab on
your browser.

Safari: Preferences -> Security. For more information, please check out Apple Support or the Help tab on your browser.

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